Chemical Use

Plant protection products and fertilisers are useful tools in turfgrass management and can even be used for conservation gain (e.g. to selectively remove grass from within heather areas or to eradicate non-native invasive plant species). However, they are potentially harmful to the environment and human health and should be used, stored and disposed of responsibly to minimise risks to wildlife and the wider environment.

The commercial use of plant protection products is subject to national and international legislation. Codes of practice are also available that offer guidance and best practice advice in the use of plant protection products. The main statutory regulations and voluntary codes of practice relating to the use, storage and disposal of plant protection products in order to protect the environment are described in this resource. Legislation covering health and safety requirements is not covered.

1. Integrated Pest Management

Integrated Pest Management (IPM) is a best practice system of turfgrass management that places an emphasis on preventing, rather than controlling, pests and disease by utilising ‘cultural techniques’ to reduce disease incidence and thus chemical use. Among other things, this includes ‘switching’ to remove early morning dew and aeration and top dressing to remove thatch (partially decomposed grass material stored at the base of the plant). Dew and thatch provide conditions that encourage disease and pest activity.

Integrated Pest Management involves:

Regular monitoring and record keeping to identify pest and diseases quickly and accurately;

Analysis of local environmental conditions encouraging the disease or pest outbreak (low nutrient status in the soil, a build up of thatch, shading of the turf, lack of air movement, etc.);

Altering local environmental conditions, where possible, to prevent or discourage the pest or disease in future, e.g. favouring turfgrass varieties with high disease resistance, improving aeration to help breakdown thatch and selectively removing trees to improve light and air flow close to playing surfaces.

Agreement upon ‘damage thresholds levels’ for weeds and pests (e.g. percentage cover of weed species on a tee or green) below which level they will be tolerated.

If, despite preventative measures, the agreed ‘damage thresholds’ are exceeded then control methods may need to be used to suppress the pest population. If biological controls are available, their use should be considered. When selecting a chemical control, choose plant protection products which poses least risk to the environment, e.g. chemicals which selectively affect the target species, leaving other species unharmed, should be used in preference to broad spectrum chemical controls. Chemicals with low persistence (i.e. are quick to degrade and lose their potency) and low mobility should be chosen above persistent chemicals that will easily leach beyond their intended target area.

2.1 Environmental Risk Assessments

Plant protection products must only be used following a thorough environmental risk assessment, which must include an assessment of site-specific environmental factors, e.g. proximity to water courses, whether the ground is steeply sloping, the type of vegetation cover, etc. An environmental risk assessment must take account of the effects of plant protection products on non-target plant and animal species and any anticipated effect on environmental quality.

The product with the best environmental profile, consistent with the desired level of efficacy, must be selected for use. When making an application the product label statutory recommendations (directions for use) must be followed to comply with the product approval (conditions under which the product has been approved for use).

2.2 Control of Substances Hazardous to Health Regulations (COSHH) 2002

The Control of Substances Hazardous to Health Regulations (COSHH) 2002 ensure that employers protect their employees and members of the public who may be exposed to chemicals or other hazardous substances. The regulations apply to all substances classified as ‘hazardous’, i.e. toxic, harmful, irritant or corrosive.

The basic principle underlying COSHH is that the risks associated with the use of any substance hazardous to health must be assessed before it is used and the appropriate measures must be taken to eliminate or control the risk.

Moe information on COSHH is available on the Health and Safety Executive website.

2.3 Local Environment Risk Assessment for Pesticides (LERAP)

Water features on golf courses can be vulnerable to leaching of plant protection products applied to playing areas and best practice techniques must be adhered to when applying products close to surface water and wetlands.

LERAP (Local Environment Risk Assessment for Pesticides)guidelines applies to spraying operations close to water features and ditches (even when dry) carried out using a boom sprayer or broadcast air-assisted sprayer. Plant protection products are classed as LERAP A or LERAP B depending on their potential to cause harm to the water environment.

LERAP A products require that a minimum five metre untreated buffer zone be left between the area to which plant protection products are applied and the top of the bank of any adjacent watercourse or waterbody. This buffer zone cannot be reduced.

The buffer zone for LERAP B products can be reduced if a Local Environmental Risk Assessment for Pesticides (LERAP) is undertaken prior to making an application. This takes account of the size of the water body, the dose rate used and the method of product application. The buffer zone for LERAP B products cannot be reduced beyond one metre. LERAP record sheets must be generated and stored for all products applied to the golf course as part of spraying records for the site. The application of LERAP B products whilst keeping a five metre buffer zone in place does not require a LERAP assessment but the decision to stick to the label buffer zone must be included in spray records.

2.4 Weather conditions

All reasonable precautions must be taken to prevent spray drift, excessive volatilisation and contamination of run-off during application of plant protection products. Weather considerations include:

Applications must only be made during ideal wind conditions (c. 2 – 4 km/h or Force 2 on the Beaufort Scale) and wind conditions must be assessed before deciding to spray.

Spraying must not be undertaken during rainfall and must not be undertaken if imminent heavy rainfall is forecast. Some product labels state the minimum amount of time before the product is rainfast (e.g. glyphosate is rainfast in 6 hours) and these timescales must be considered when choosing whether to spray on any particular day. The efficacy of the product may be reduced if the interval before rainfall is shorter than expected.

Plant protection products must not be applied to frozen ground due to the increased risk of run-off.

In summer, chemical products must not be applied during periods of high air temperatures to reduce the possibility of volatilisation losses.

Plant protection products must only be applied under effectiveweather conditions e.g. certain fungicides products will only be taken up by the grass when actively growing (generally this means air temperatures above 8ºC).

2.5 Engineering controls

Spray quality, pressure and dose rate also have an impact upon the likelihood of spray drift. Engineering controls can help to reduce the potential for drift, e.g. the use of twin-fluid nozzles, air-induction nozzles or shrouded-boom sprayers. Greenstaff must take care to choose the most appropriate spray equipment for each specific area of the golf course and to adjust spray pressure to minimise spray drift. For example, spot treatment of herbicide using backpack sprayers must be used in preference to blanket sprays treatments using boom sprayers whenever practicable.

Only NPTC (National Proficiency Test Certificate) qualified personnel must undertake applications of plant protection products on golf courses. The NPTC certificate must be appropriate to the specific equipment used and the environmental circumstances. All training must be logged and accurate records kept of any training recommendations made or completed.

Personal protective equipment (PPE), such as masks, gloves and coveralls, must be supplied by golf clubs to all relevant staff and must be worn by all spray operators when mixing and applying products and cleaning spray equipment (the equipment needed must be determined with reference to the product label).

Records must be kept on each plant protection product received by the golf club, from delivery and use through to safe disposal of packaging and waste product. Systematic pesticide application records must be kept for all applications of plant protection products for a minimum of three years. Sprayer maintenance records and NSTS (National Sprayer Testing Scheme) records must be kept for a minimum of five years.

In addition to recording plant protection product applications, there is a requirement to undertake a COSHH assessment (under the Control of Substances Hazardous to Health Regulations 2011) and to retain COSHH assessment records.

2.7 Storage of plant protection products

Plant protection products stored on the golf club premises must be stored in line with guidelines set out in the Agricultural Information Sheet 16 : Guidance on Storing Pesticides for Farmers and other Professional Users.

In addition, it is best practice to draw up an Emergency Plan for the chemical store which must provide:

A plan of the store buildings and surrounding area

A drainage system and water supply site plan

The location of drain bungs, gully covers, cut off valves and sand bags

Contact details for emergency services and pollution prevention and control authority

The Emergency Plan must be kept close to but not within the chemical store and supplied to key stakeholders such as the local fire authority, the local authority environmental health department and the local Environment Agency office.

If a plant protection product spillage occurs it must be contained and absorbed with inert absorbent materials such as sawdust or cat litter (appropriate Personal Protection Equipment must be worn). If spillages are large and cannot be easily contained or have entered into a water course then the golf club must contact the Environment Agency for further advice.

2.8 Mixing of chemicals and washdown of machinery

The filling and mixing of spray tanks (both knapsack and boom sprayers) must be undertaken on top of a temporary bund, within a bunded area e.g. a concrete pad, within the greenkeeping compound. Similarly, spraying equipment and all machinery that is used within treated areas must be washed down on top of a bunded washpad or biobed.

Run-off from this bunded area must drain to an appropriate water treatment system, either a combination of an oil/water separator and biobed or a mechanised cleansing unit.

2.9 Storage and disposal of waste pesticide packaging

Waste pesticide packaging must be triple rinsed and then stored in sealed containers until they can be removed by an approved waste contractor for safe disposal or returned to the manufacturer if possible. Any waste pesticide concentrate must be stored in the chemical safe until it can be collected by an approved contractor.

3. Fertiliser storage and use

Fertiliser use must be confined to in play areas (tees, fairways, greens and green surrounds). The primary aim of fertiliser use must be to combat wear and tear on grass plants only. Excessive fertiliser applications that increase grass growth rates above what is required to combat wear is a waste of an expensive, energy intensive resource and will also impact negatively on the quality of playing surfaces.

3.1 Proximity to surface water features

Ideally, a minimum untreated buffer zone of three metres must be maintained around surface water features and wetland areas. Fertiliser must not be applied within this buffer zone. On steep slopes (> 10º) this buffer zone may need to be extended to 6 m to prevent fertiliser entering water as runoff.

3.2 Weather conditions

Fertiliser applications must be timed to minimise potential losses through run off, leaching or volatilisation (loss of nitrogen as ammonia gas). Weather considerations include:

Fertiliser must not be applied during rainfall and must not be applied if imminent heavy rainfall is forecast.

Liquid fertiliser must not be applied to frozen ground due to the increased risk of run-off

In summer, fertiliser must not be applied during periods of high air temperatures to reduce potential volatilisation losses.

3.3 Engineering controls

Methods of fertiliser application must be tailored to each individual area of the golf course, to minimise the drift of fertiliser into non-target areas and to minimise potential run-off. The form of fertiliser, e.g. liquid, powder or granule and the … e.g. quick or slow release must all be considered when choosing the most appropriate fertiliser for a site.

3.4 Operator training

No statutory qualifications or protective clothing are required for fertiliser application. However, any inexperienced members of the greenkeeping team must receive appropriate in-house training before applying fertilisers.

3.5 Fertiliser storage

Fertiliser must be stored in a clean, dry environment away from other chemicals and must be stored on top of wooden or plastic pallets to raise the fertiliser off the ground. Any opened fertiliser containers must be tightly re-sealed.

Fertiliser materials are normally supplied with a Product Safety Data Sheet indicating any safety precautionary measures which need to be taken and these must be adhered to.

The Control of Substances Hazardous to Health Regulations 2011 requires that safety plans be produced for any hazardous material stored on site. Specific controls apply to the storage of ammonium nitrate which is an oxidising agent and, as such, has the capability of causing fire or explosion. If ammonium nitrate is to be stored on site, then COSHH Regulations will apply.

3.6 Filling of application equipment and washdown of machinery

The filling of fertiliser application equipment and machinery must be carried on hard standing, within a bunded area e.g. a concrete pad, within the greenkeeping facility. Similarly, application equipment and all machinery used within treated areas must be washed down on top of a bunded hard standing washpad.

Run-off from this bunded area must drain to an appropriate water treatment system, either a combination of an oil/water separator and dedicated reedbed or a mechanised cleansing unit.

3.7 Disposal of waste fertiliser and fertiliser packaging

Waste fertiliser packaging can be disposed of as normal controlled waste.

4. Legislation

The main statutory regulations and voluntary codes of practice relating to the use, storage and disposal of plant protection products in order to protect the environment are described below. Any information on legislation covering health and safety requirements should not be considered fully comprehensive and further advice can be found on the Health and Safety Executive website. All legislation information is correct as of January 2011. Legislation changes regularly and golf clubs should check the news section of the greener golf website for information on important changes.

4.1 The Sustainable Use Directive (SUD) (2009/128/EC)

The Plant Protection Product Regulations (PPPR) 2005 will be replaced by new legislation by November 2011, which will take into account the Sustainable Use Directive (2009/128/EC) introduced by the European Commission in 2009. Further information on The Sustainable Use Directive is available in a summary presentation from CRD available on the Amenity Forum website.

Since 1993, under the Plant Protection Product Regulations and the more recent Sustainable Use Directive, all products new to the market must undergo a rigorous approvals process and existing products have been subject to a review of approval. Products which cannot demonstrate strict safety limits and low environmental risks have gradually been withdrawn from the market. Any products which have yet to be reviewed under the Plant Protection Products Directive and more recent Sustainable Use Directive are approved under the Control of Pesticide Regulations until they have been reassessed.

In practice, this means that some pesticide products approved before 1993 and that are currently for sale and approved for use may be withdrawn from the market. Products are generally phased out with a set cut off date by which all remaining products must be sold and a later cut off date by which all products that have been sold must be used up. After this date it would be illegal for the golf club to use the withdrawn product on the golf course.

Golf clubs must regularly check the status of product approvals to ensure that no product routinely used by the club and stored in the pesticide store has passed its use up date. Product approvals can be easily checked using the searchable databases maintained by the Chemical Regulation Directorate (CRD) (part of the Health and Safety Executive).

An impact assessment conducted by CRD (formerly PSD (Pesticide Safety Directorate)), outlines the most likely substances to be banned under the new SUD legislation.

4.2 Wider environmental legislation

Several pieces of legislation designed to protect the wider environment are relevant to the use and storage of plant protection products including:

The Water Framework Directive (2000/60/EC)

The Environmental Permitting Regulations 2010

Further information on this wider environmental legislation is provided in the Water Use Resource Section within the Greener golf website.